American Gas Association
EPARulemakingEPA-HQ-OAR-2018-0048

Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NSR): Project Emissions Accounting

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Last modified
Apr 13, 2022
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closed 2485d ago
American Gas Association filings
1

Activity

American Gas Association filed 1 comment on this docket between Oct 10, 2019 and Oct 10, 2019. 19 other organizations filed here. The comment window closed 2485d ago.

What American Gas Association filed (1)

Oct 10, 2019· Comment submitted by Pamela A. Lacey, Chief Regulatory Counsel, American Gas Association (AGA)· EPA-HQ-OAR-2018-0048-0063

The American Gas Association (AGA) submits the attached comments in this docket to strongly support EPA's proposal to clarify how to account for project emission increases and decreases in step 1 of the new source review (NSR) applicability test.

Abstract

The Environmental Protection Agency (EPA) is proposing to revise certain New Source Review (NSR) applicability regulations to clarify the requirements that apply to sources proposing to undertake a physical or operational change (i.e., a project) under the NSR preconstruction permitting program. Under this program, an existing major source proposing to undertake a project must determine whether that project will constitute a major modification following a two-step applicability test and thus be subject to the NSR preconstruction permitting requirements. The first step is to determine if the proposed project will cause a ‘‘significant emissions increase’’ of a regulated NSR pollutant (Step 1). If the proposed project is projected to cause such an increase, the second step is to determine if there is a ‘‘significant net emissions increase’’ of that pollutant (Step 2). In this action, we are proposing to revise our NSR applicability regulations to make it clear that both emissions increases and emissions decreases that result from a given proposed project are to be considered at Step 1 of the NSR major modification applicability test. In addition, this proposal replaces and withdraws the agency’s 2006 Project Netting Proposal.

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